Three Days Left to Submit Suggestions to Repeal EPA Regulations

Guest essay by Leo Goldstein

I would like to bring to the attention of American readers that they can submit comments on the EPA regulations in accordance with Executive Order 13777, “Enforcing the Regulatory Reform Agenda,” signed by President Trump on February 24, 2017. The deadline for submission is May 15, so we have only three full days. H/t John Droz, Jr..

Comments can be as short as one line or as long as the regulations.gov site allows. You can also include audio or video attachments, although only the written comments will be considered an official statement. Off the top of my mind, I can recommend NIPCC Summaries, many articles by Prof. Richard Lindzen, as well as various materials from this outstanding resource, WattsUpWithThat. If a web page cannot be adequately saved as a PDF file, its content can be copied to Word then saved as PDF. You are also welcome to attach The Brief Summary of Science, written by me with input from Prof. Fred Singer, Prof. Will Happer, and Prof. Richard Lindzen (but not formally endorsed by them).

The comments will be received by the newly-assembled Regulatory Reform Task Force, which is to

attempt to identify regulations that:

(i) Eliminate jobs, or inhibit job creation;

(ii) are outdated, unnecessary, or ineffective;

(iii) impose costs that exceed benefits;

(iv) create a serious inconsistency or otherwise interfere with regulatory reform initiatives and policies;

(v) are inconsistent with the requirements of section 515 of the Treasury and General Government Appropriates Act, 2001 (44 U.S.C. 3516 note), or the guidance issued pursuant to that provision in particular those regulations that rely in whole or in part on data, information, or methods that are not publicly available or that are insufficiently transparent to meet the standard of reproducibility; or

(vi) derive from or implement Executive Orders or other Presidential directives that have been subsequently rescinded or substantially modified.

Read the Tips for Effective Comments & Restrictions. The most important ones, in my opinion, are:

● “Be concise but support your claims. Explain your views as clearly as possible, avoiding the use of profanity or personal threats. Explain why you agree or disagree; suggest alternatives and substitute language for your requested changes. Provide specific examples to illustrate your concerns and suggest alternatives.

Base your comments on sound reasoning, scientific evidence, and/or how you will be impacted by the agency’s proposal. Describe any assumptions and provide the technical information and/or data that you used. If you estimate potential costs or burdens, explain how you arrived at your estimate in sufficient detail to allow for it to be reproduced.

Address trade-offs and opposing views.

The comment process is not a vote – one well-supported comment is often more informative to the agency than a thousand form letters.

Multimedia submissions (audio, video, etc.) must be accompanied by a written comment. The written comment is considered the official comment and should include discussion of all points you wish to make.

EPA will generally not consider comments or comment contents located outside of the primary submission (i.e. on the web, cloud, or other file sharing system).

The inclusion of any copyrighted material without accompanying proof of one’s explicit right to redistribute that material will result in the comment being blocked from online viewing at Regulations.gov.

So far, this opportunity has been hijacked by environmental activists and their followers. Meanwhile, the former mainstream media was saying that public input was not solicited.

The dream came true: we, The People, can petition the government to repeal any EPA regulation and the government will listen. But we only have three days to do so. Go to the Evaluation of EPA Regulations on regulations.gov, click the Comment Now button at the top right, speak your mind, and attach supporting documents.

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May 12, 2017 4:56 pm

Beat the left at whining? That would be like my local Girl Guides taking on the All Blacks at rugby.

TA
Reply to  cephus0
May 13, 2017 5:24 am

“whining”
I leaned something the other day. I’ve noticed that some of our other English-speaking countries spell “whining” as whinging. Until a couple of days ago, I thought this was just a difference in spelling, but then I heard an Aussie lady pronounce it, and it is pronounced differently from the American version. Whining is pronounced “wine-ing” whereas she pronounced whinging as “win-jing”. I thought that was interesting.

EricHa
Reply to  TA
May 13, 2017 9:22 am

Two different words although somewhat similar.
whine
/wʌɪn/
verb
gerund or present participle: whining
give or make a long, high-pitched complaining cry or sound.
“the dog whined and scratched at the back door”
synonyms: hum, drone, sing
“the lift began to whine”
•complain in a feeble or petulant way.
“she began to whine about how hard she had been forced to work”
synonyms: complaint, complaining, grouse, grousing, moan, moaning, moans and groans, grouch, grouching, grumble, whining, carping, muttering, murmur, murmuring, whispering;
whinge
/wɪn(d)ʒ/
British informal
verb
gerund or present participle: whinging
complain persistently and in a peevish or irritating way.
“stop whingeing and get on with it!”
synonyms: complain, grouse, grouch, grumble, whine, moan, carp, mutter, murmur, whisper;

TA
Reply to  TA
May 13, 2017 11:28 am

Thanks for that explanation, EricHa.

AP
May 12, 2017 5:04 pm

I wish we had this opportunity in Australia. We are going the other way.

Clive08
Reply to  AP
May 12, 2017 10:52 pm

I sent comments to the Queensland government version on renewable energy. They had a resident guard dog who ridiculed and misrepresented all my submissions. Virtually all the other submissions were from windmill/solar panel enthusiasts..

nigelf
Reply to  AP
May 13, 2017 6:14 am

Only for now. Eventually sanity will prevail and then the decision becomes how do we get those billions of dollars back that were malevolently spent on this scam and how many of the top people involved spend the rest of their lives behind bars.
Legally banning from public office anyone who supports the view that “humanity controls the climate” would be a good start.

Resourceguy
May 12, 2017 5:16 pm

I sent four so far.

Nick Stokes
Reply to  Resourceguy
May 12, 2017 6:07 pm

“one well-supported comment is often more informative to the agency than a thousand form letters”

Duncan
Reply to  Nick Stokes
May 12, 2017 7:44 pm

Nick, while I don’t support your views, you are as sharp as a tack. Good for you calling him out.

ClimateOtter
Reply to  Nick Stokes
May 13, 2017 3:18 am

From the sounds of things over there, nick, your side is sending thousands of form letters, filled with UNINFORMED comments.

Samuel C Cogar
Reply to  Nick Stokes
May 13, 2017 5:29 am

Duncan – May 12, 2017 at 7:44 pm

Nick, while I don’t support your views, you are as sharp as a tack. Good for you calling him out.

What kind of brownnosing silliness was that, ….. an attempt to impress Nick S or what?
Me thinks Resourceguy sure was pretty darn smart to “send four (4) different issue requests” …… rather than “one (1) request” containing four (4) different issues.
Most all normally intelligent people knows that “you don’t put all your eggs in one (1) basket”.

Mickey Reno
Reply to  Nick Stokes
May 13, 2017 5:44 am

But of course what they really mean is, “one good letter supporting our interest group, our public sector jobs, our funding of Academic research spending, even if that research is pure garbage, is often more influential than a thousand letters who oppose “us” because their actual expenses will rise.”
I’m going to send a suggestion. I’m 97% sure it will be ignored.

Reply to  Resourceguy
May 12, 2017 11:17 pm

Here’s are excerpts of what environmental activists are posting, followed by my editorial comments. We could do better than these. And even if we don’t have the time to do better, it would be quite easy to do as well. This looks like a voting situation where quantity overrides quality (currently 24,338 entries), so have at it.
“voters would rather drink clean water and breathe fresh air than give more money to the failing coal business”
** coal businesses using up-to-date technologies do not impact air and water quality, and are failing because of government policies
“EPA is integral to protecting the environment, and by extension, human health”
** the EPA actually did some good years ago, but recent regulatory over-reach just kills jobs without providing significant empirically quantifiable benefits
“ridiculous that we are wasting our time trying to change perfectly good laws”
** laws whose costs exceed the benefits are NOT “good laws”
“Let’s air [sic] on the conservative side of protecting our resources”
** let’s regulate based on solid empirical evidence rather than vague fears
“regulations are what is [sic] protecting us. do not chnage [sic] the clean power regulations”
** regulations with negligible benefits and large associated costs do NOT protect us
“erosion of these regulations risks putting the short- and long-term health and safety of all Americans at risk”
** elimination of unnecessary regulations imposes no risks

Reply to  Ralph Westfall
May 12, 2017 11:25 pm

Here’s a real classic, in it’s entirety:
“Getting rid of the EPA is one of the most insane, assinine [sic], and complete [sic] stupid things that you could possibly do! What is wrong with you people? Clean air, clean water, clean soil, clean living; what is wrong with that?? Why are you trying to push America back to the furthest distant possible spot in time when every other country is moving forward. You obviously do not have any children that you plan on leaving behind you. Flint MI water, our dying oceans, toxic air levels, this is not the 70’s. I will watch you and I will vote accordingly, against ANYONE that tries to push this through. You people are not just stupid, but you are insane. Next, you’ll want to make our Federal lands public and sell off our most beloved parts of this country. IF YOU WANT TO REMOVE THINGS LIKE THIS, THAT ACTUALLY MAKE AMERICA GREAT, YOU DESERVE TO LEAVE THIS COUNTRY. PERIOD. This land is our land….MINE AND YOURS, not yours. I am pissed and I am watching you.”
https://www.regulations.gov./document?D=EPA-HQ-OA-2017-0190-23429

MarkW
Reply to  Ralph Westfall
May 15, 2017 6:20 am

And I am watching you.
How utterly fascist of him.

Lorne White
Reply to  Resourceguy
May 13, 2017 2:27 am

Please post your recommendations here for the 4 EPA regs you want changed.

Reply to  Lorne White
May 13, 2017 9:20 am

recommendations here for the 4 EPA regs you want changed

All the ones whose direct and indirect costs demonstrably exceed the benefits.

Resourceguy
Reply to  Lorne White
May 14, 2017 7:07 am

Not with Sierra Club trolls monitoring this site.

Resourceguy
Reply to  Resourceguy
May 13, 2017 1:49 pm

Make that five

Reply to  Resourceguy
May 14, 2017 5:37 am

Have they been published? Mine was not.

Janice Moore
May 12, 2017 5:34 pm

Success! (about 5 minutes ago)
My comment:
Thank you for the opportunity to urge you to re-open the illegal rulemaking about human CO2 emissions, i.e., the anti-science “endangerment finding.”
Please see my attached Memo.
Janice Moore

Your comment was submitted successfully!

There were only about 50,000 comments already!
I’m not worried. “God and one are a majority.”
We shall see what God does… (many are praying).
Thank you, Mr. Goldstein, for the opportunity to fight for TRUTH!
#(:))

Resourceguy
Reply to  Janice Moore
May 13, 2017 2:02 pm

Me too, all five of them.

SMC
May 12, 2017 6:10 pm

Looks like a lot of Watermelons posting anonymously… Tried looking for your comment Janice, couldn’t find it, maybe it hasn’t posted yet.

Janice Moore
Reply to  SMC
May 12, 2017 6:41 pm

Hey! Thanks for looking for me SMC. 🙂

JBom
May 12, 2017 6:11 pm

Reminds me of the AGU abstract submission process to the Fall Meeting.
Usually, in the last 27 years, 95% of the 20,000+ abstracts are submitted in the last 30 minutes of the submission window.
Ode to Joy

JBom
Reply to  JBom
May 12, 2017 6:13 pm

JBom
Reply to  JBom
May 12, 2017 6:26 pm

Or perhaps the Tchaikovsky “1812” with real Howitzers! And the orchestra in Full Combat Gear! Ha ha

Janice Moore
Reply to  JBom
May 12, 2017 7:07 pm

You nailed it with the second one, JBom (I’m going to steal your name! Whenever I do something spectacularly wonderful — at least twice a day — I’ll merrily shout, “J-Bom{b}! 🙂 ).
The baroque interp. of the first was what sunk that one for me. Here’s a ROCK version!

(youtube)
(verse 4 — revised)
Skeptics, join the mighty chorus
which the mighty stars began,
Feynman, Daly, Carter, Lewis
vindicated to a man.
Ever singing, march we onward,
victors in the midst of strife.
Observations had the last word
in the triumph song of life!

#(:))

May 12, 2017 6:37 pm

WUWT Readers, I have another article I’d really appreciate some reviews of. Also, it may provide some arguments to take to the EPA.
4 Graphs That Demonstrate Why The IPCC Climate Models Will NEVER Be Accurate
If I am correct in properly identifying the motives and intent of the fraud, the divergence between the ground measurements and satellite data will continue to widen with time. In 10 years, an understanding of the crime detailed above and an update of the following chart is all Congress should need to present an open and shut case against the climate alarmists that have defrauded the American taxpayers, corrupted real science, and destroyed the credibility of our media and educational system.
https://co2islife.wordpress.com/2017/05/13/4-graphs-that-demonstrate-why-the-ipcc-climate-models-will-never-be-accurate/

Russell Johnson
May 12, 2017 6:54 pm

EPA is a scrrilous enemy of scientific progress in America, it’s a Fascist pawn of regressive bureaucratic group think that has ceased to promote American values. Defunding 100% is too kind a fate for an outmoded agency.

Duncan
May 12, 2017 7:00 pm

“So far, this opportunity has been hijacked by environmental activists”
Not to be defeatist, on the contrary, I often find these “write the editor”, “write your senator” type commitments are predisposed to the very people who support the proposition in the first place. Difficult to get people to commit to a non-problem with zealot action. Yet those who are passionate, even in the minority, get the message out because they can persist and are willing to take the time. Point being, even a one sentence non-support comment goes a long way, not a lot of thought needed, just DO IT! If you can add more great. Not to take away from the article but most people don’t have the time or wherewithal to be “concise” or robust in a submission. Support can be just about simple numbers too.

Duncan
Reply to  Duncan
May 12, 2017 7:35 pm

I just sent my ten-sentence reply and I am a Canadian (too easy, hehehe). Everyone get out, from-whatever country and just send something that you are feeling, of not more.

May 12, 2017 8:27 pm

The EPA had a legitimate purpose when it was created by President Nixon to clean-up terribly polluted water like the Great Lakes and excessively dirty air in major industrial areas. Unfortunately as it was meeting success the EPA became desperate to justify a redefined, misguided mission. The EPA should have been disbanded in the mid 1990s. Instead it was allowed to become a totalitarian government monster – kill it, before it kills us.

Reply to  pyeatte
May 12, 2017 8:58 pm

Congress forgot to attach a leash.

RockyRoad
Reply to  Gunga Din
May 12, 2017 9:48 pm

There is a fund leash; problem is, much of the funding ends up in the representative’s pocket or district.

Resourceguy
Reply to  Gunga Din
May 14, 2017 7:04 am

Congress needs to add felony charges to the illegal acts of federal employees working with protest groups from inside the agencies. They also need to withhold the pension of John C, Beale,

SocietalNorm
May 12, 2017 9:00 pm

My submission isn’t about climate change, but here it is for your info:
ALL EPA regulations whose rationale is based on human health put into law after the year 2000 be eliminated
and a fast-track should be created for re-implementation of specific regulations that have direct health benefits approved by Congress.
(Graphs mentioned are all in an attached file, as well as the referenced text)
……………………………….
Comment:
We know that as we try to make our environment in the United States cleaner and cleaner, we must spend (or forgo wealth) higher and higher amounts of money to comply with more and more regulations for less and less difference in the environment. This is the law of diminishing returns, or perhaps, in Quality parlance, you could call this the Pareto Principle. The most oft-cited reason for regulations is the reduction in the incidence of cancer. Let’s look at statistics for the incidence of cancer in the United States.
https://www.cancer.org/content/dam/cancer-org/research/cancer-facts-and-statistics/annual-cancer-facts-and-figures/2017/cancer-facts-and-figures-2017.pdf
Cancer Facts and Figures 2017 from the American Cancer Society – Figure 1 (Figure 1 for reference). Trends in Age-adjusted Cancer Death Rates* by Site, Males, US, 1930-2014 – shows that the age-adjusted incidence of cancer has significantly dropped in recent decades for 3 types of cancer, lung, prostrate, and colon cancer. (Stomach cancer has also been dropping, but has been dropping significantly since the 1930s, so the trend is not likely due to EPA regulations). Other forms of cancer listed in Figure 1 do not show a drop.
https://www.cancer.org/latest-news/cancer-facts-and-figures-death-rate-down-25-since-1991.html
from the site – Cancer Facts and Figures: Death Rate Down 25% Since 1991, under the heading of Understanding the decline in prostate, lung, and colorectal cancer rates – we can see that PSA blood tests, smoking, and colonoscopys are the primary reasons for the drops in these cancers. Also, there are very well known causes of lung cancer such as asbestos exposure and coal mining.
The text is reprinted below my text as well as in the attachment.
Next, if you go to https://seer.cancer.gov/statfacts/html/all.html website of the National Cancer Institute you can see the drop in overall cancer rates. However, this drop is almost entirely due to the drop in lung, prostrate, and colon cancers. Incidence rates for other cancers are generally flat or increasing (these rates are not caveated in the same manner as the American Cancer Society numbers). [Click on the Cancer Stat Facts for each type of cancer on the left hand side of the page to view the values for each type.]
Therefore, despite hundreds of billions of dollars of wealth spent and forgone, EPA regulations have been ineffective in reducing the rate of cancer in the United States in recent years. What has reduced the rate of cancer has been more scientific knowledge about cancer and public heath campaigns such as “stop smoking” at thousandths of the cost of recent EPA regulations.
For this reason, I submit that ALL EPA regulations whose rationale is based on human health put into law after the year 2000 be eliminated. Almost all regulations that have direct health benefits (such as those for asbestos and lead paint) were put into place prior to that time. There may be existing regulations that have direct health benefits. For that reason, a fast-track should be created for re-implementation of specific rules approved by Congress.
……………………………………………
I’m sure that the numbers can be poked at (feel free), but it’s what I could dig out in a couple of hours. In any case, I believe the cost-benefit ratio is far, far in the favor of more scientific research and public health programs and elimination of EPA regulations that cause poverty.

Joe Crawford
Reply to  SocietalNorm
May 13, 2017 8:04 am

+… …+

Dr. S. Jeevananda Reddy
May 12, 2017 9:02 pm

EPA role now is critical. They can now give more thrust to pollution aspects that critical impact human health — drug manufacturing, hospitals creating more health risks — [CO2 is not a pollutant that cause health hazards]. Here we must remember the fact that technology is not going to save the humans from health disasters except keep them alive under drug. The air we breathe is polluted, the water we drink is polluted, the land we grow crops is polluted and thus the food we eat is polluted. This needs application of precautionary principle. To act in this direction EPA plays important and critical role. EPA needs strengthened in this direction.
Dr. S. Jeevananda Reddy

SocietalNorm
Reply to  Dr. S. Jeevananda Reddy
May 13, 2017 8:38 am

The air we breathe in the U.S. has never been cleaner in cities. People used to burn wood, coal, and peat in their homes – filling the air with pollution. EPA regulations often mandate cleaning water to levels far beyond what naturally occurs in rivers and streams. [By the way, the largest source of water pollution in the past year was the EPA.] We’ve never had so much abundant healthy food in the history of the world. Our heath problems are with obesity, not with bad food.
If EPA regulations had an effect on health, it would be evident in the statistics.
The biggest factor in poor health is poverty.
The largest strain on our society is men without good jobs. This hurts in the formation of families. Also, having large numbers of men without jobs and family responsibilities historically causes major social problems.
Putting forth unthinking bromides about air and water being polluted without seriously looking at the issues only causes misery and pain.

Dr. S. Jeevananda Reddy
Reply to  SocietalNorm
May 13, 2017 5:15 pm

SocietalNorm — Do you think pollution is not an important issue to USA?
Unplanned urbanisation, population explosion, agriculture and uncontrolled sewage discharge into rivers and lakes/tanks are primary reasons behind the rise in surface water pollution. Gulf of Mexico turned into a dead zone spreading over thousands of square kilometers with runoff that contains residues of chemical fertilisers & sprays from agricultural farms carried through Mississippi River in USA. We are using groundwater indiscriminately but we are not taking any action on recharging the groundwater and thus causing water pollution. The surface polluted water also polluting groundwater.
Access to quality water is essential for human health and human development. Both are at risk if we fail to stop the pollution.” Stan Cox’s ‘Sick Planet: Corporate Food and Medicine,’ argues that corporate food and medicine industries are destroying environments and ruining living conditions across the world.
Chemical fertiliser based food production and GM based food production has major health hazards including body disorders. Have a seen this in USA before chemical fertiliser use in agriculture?
Dr. S. Jeevananda Reddy

SocietalNorm
Reply to  SocietalNorm
May 14, 2017 12:50 pm

No, Dr. Reddy, air and water pollution is not a big issue in the USA. Generally, the air is healthy and the water is good. The year 2000 was about the time where regulations started to get to the point where we were requireing a cleaner than naturally occuring environment. This isn’t China or a third-world country. Regulations are quite strict. You just stating that “the air we breathe is polluted, the water we drink is polluted, the land we grow crops is polluted and thus the food we eat is polluted” is just a silly statement. Surface water pollution is far less than it used to be. There is no dead zone in the Gulf of Mexico and surface water is not polluting groundwater. The campaign against GMO food has caused tremendous poverty and starvation in Africa – preventing increased food yields like the U.S. has been able to achieve. It is a moral abomination. Also, if we went to the level of food productivity we had prior to chemical fertilizers, we could not support the population of the U.S. (which is growing slowly, in Africa the population is exploding), much less feed much of the rest of the world.
Your boutique organic food uses more land and resources for a given amount of food than current farming methods. It is a luxury good for the elite that causes less food and higher prices for those not so rich.
The place I do share your concerns is with the reduction in the level of the aquifer under the midwest. However, it is the green activists who do not want dams or other water resource control measures. This is also made worse by ethanol production from corn, which uses resources unnecessarily, is terribly expensive, causes other crops to be grown on less-productive land using more water, and after all these years is just getting to the point where it replaces more fossil fuel than it uses. Essentially, we are just burning up all the resources put into creating ethanol, including the aquifer water, for nothing.

Dr. S. Jeevananda Reddy
Reply to  SocietalNorm
May 15, 2017 4:05 am

SocietaNorm — I travelled by car from North Carolina to Detroit. In Detroit if you go out and come back home, you smell like hell. About no dead zone in Gulf of Mexico is wrong. In fact environmental movement started in 1960-70s relating to the chemical inputs in green revolution technology. The mnc compelled UN to shift the movement on to global warming – carbon credit. But the chemicals causing the surface water pollution and with the time this increased. FAO put food waste globally as around 30% — I put this 40-50% in India [presented in 2011 on all-India Radio talk] and thus wasting to that extent the natural resources. Also, most of the GM cases use chemical inputs and irrigation and subsidised. GM only help to monopolize seed industry. Bt-Cotton that is now only GM seed in use since 2002 is already reached a plateau even after changing Bt three times in 13 years. The pests-diseases increased and input costs increased and farmers suicides increased in the five states where Bt-cotton is grown. In fact high yielding seeds of private sector were converted in to Bt and sold at several times higher than high yielding seed [which can be used in the next season also]. The GM yield is bounded by the high yielding seed only but its life is short.
I travelled and worked in several African countries like Mozambique & Ethiopia and south American countries like Argentina and Brazil. Though MNCs are trying to push their GM but local population rejected it.
Indian farmers developed best system of organic farming that out yield GM with nutricious security. Developing countries needs this instead of paying MNC trillions of dollars on royalty and chemicals.
Dr. S. Jeevananda Reddy

SocietalNorm
Reply to  Dr. S. Jeevananda Reddy
May 15, 2017 2:45 pm

Dr. Reddy,
As far as Detroit is concerned, it is in compliance with all current (even new) EPA regulations. Smells are not EPA regulated. http://www.michigan.gov/documents/deq/deq-aqd-amu-2015_Annual_Air_Quality_Report_536005_7.pdf
You are correct about the Dead Zone in the Gulf of Mexico. I was confusing it with something else called a “dead zone.” Yes, fertilizer runoff has been an issue and was part of the reason for Lake Erie dying in the late 1960’s – which gave rise to a lot of the impetus of the ecology movement in the US. Laundry detergents using phosphates (which of course got in the water and promoted the algae growth) were banned, among other things.
I’m not going to try to justify seed company marketing practices – not being able to use them for more than one year so you have to keep buying them, etc. but these are not environmental concerns. It is sad that people in Africa do not get the benefits of higher crop yields due to GM because of scare tactics and because they are afraid that the EU will not buy their products. Again, non-genetically modified food is a luxury good that Europe can afford but causes lack of food in poorer areas.
I have read articles on organic farming achieving the crop yields of fertilizer, but as far as I know, it has never been on a large scale. If someone can come up with an economically efficient organic faming method that can be used on a country-wide scale that is all to the good, since, of course, fertilizers have their negatives.
I think we’ve come to a good clarification of the issues (not just our air, water, land are polluted), some of which we agree on. However, I don’t think anything you’ve stated refutes my initial point that all EPA regulations since the year 2000 have not had a measurable effect on the health of US citizens.

ossqss
May 12, 2017 9:36 pm

Opportunity knocks readers!
Step up, or shut up, comes to mind. Just sayin……….
Or maybe the old marketing thing,,,,,,,Just do it!
Ya think you would have this opportunity with Hillary?

Dodgy Geezer
May 12, 2017 11:06 pm

Please, Please, PLEASE… commission some reliable science designed to show whether CO2 is dangerous or not.
At the moment we are in the hands of the climate scientists, and they are not going to do ANY study which might show that this whole crazy hypothesis is false. SOMEONE has to do this before we can close teh whole thing down…

Jumbofoot
May 13, 2017 12:12 am

This has been on my mind for a long time. Wrong forum/venue? Also, not sure how to link to Google Drive images… click and hope for the best. =) So where did my diatribe and graphing go wrong?
Comment:
Firstly, thank you for reading this comment.
CO2 is not a pollutant. Thus any regulation by the EPA with regards to C02 should be removed (and none added until such time that the relation to C02 and temperature is proven to be causal, and not simply coincidental). In particular I found the “Endangerment Finding” to be horribly flawed, erroneous and disingenuous. And thus ANY regulation enabled or empowered by the Endangerment Finding should be removed. Additionally, activist groups should not be writing the regulations for the EPA. This would help depoliticize the agency (relegating fringe activists to, well, the fringe).
I have been studying and following the “Climate Change” issue closely for about the last decade once I became aware of the sad state of our temperature records and the circular nature of research and research funding. There is no future research money if your conclusion is that Climate Change not real (or really important). And so grants naturally seek out those who would find patterns of human caused Climate Change. It’s self-fulfilling (beware the scientific industrial complex). That’s not to say all climate scientists are corrupt. Certainly they are not. However, confirmation bias, peer pressure and personal financial pressure/motivation, could easily account for and/or skew many of the results reached. It’s human nature. Unfortunately, it also becomes less than scientific at that point.
I have included two charts that I personally created from the NASA GISS LOTI (land and ocean) data-set, and from the University of Alabama, Huntsville / UAH satellite data-set. The first is a synthesis of the two data-sets a la Michael Mann (“Mike’s Nature Trick” of adding instrument records to the tail end of a rather dubious proxy record). I only mention this as his “Hockey Stick” graph was a seminal moment in the Climate Change (Global Warming at that time) debate. And so my first graph, while based (at least loosely in the case of NASA GISS) on instrument data, I did splice the Satellite data to GISS once the UAH data was available (at about 1980). The second graph is simply the NASA GISS LOTI data-set on it’s own to eliminate my bias that the satellite record is truly more representative of the globe).
The key to these graphs is that they are in a human relateable scale. I have taken the anomaly based data from both data-sets and converted them first to degrees Fahrenheit (from Celsius), and then I have simply added 60 degrees Fahrenheit to each anomaly reading. And while this does not present a real-world temperature chart of the planet (there is no such thing), it does give you a sense of the incredible climate stability our planet truly enjoys. The charts would be representative if the Los Angeles, CA area, if it simply followed the global anomalies as presented by NASA and UAH. I am hard pressed to distinguish much of a trend – both charts are extremely flat. Certainly this cannot be the blade of “Hockey Stick”! And that lack of excitement, if you will, is the point of my argument. Nothing extraordinary is happening. There is certainly not enough going on to warrant the extreme positions and extreme remedies being proposed to “fight” climate change. The rate of change (assuming the accuracy of the data-sets) in the early 20th century is hardly different from the rate of change in the second half of the 20th century when man’s influence is theorized to have had a potential impact on C02. Also note that the anomaly data represents an average. In Los Angeles the average daily temperature swing is about 14 degrees. The urban heat island effect could easily raise the average low temperature (by slowly releasing the heat accumulated in the concrete and asphalt and other development long into the evening/nighttime). Thus raising the daily high and low average.
And so, there is nothing to see. Therefore, please consider removal of all Climate Change related regulations based upon the flawed Endangerment Finding. Thank you for your consideration.
https://drive.google.com/open?id=0B2Bt8K7dY9AHdUw2MHU0QTdKSW8
https://drive.google.com/open?id=0B2Bt8K7dY9AHVFlONDNYNGlvMkU

jon
Reply to  Jumbofoot
May 13, 2017 12:50 am

How about a simple regulation to control the EPA stating “a substance essential to human life shall not be classified as a pollutant”?

jon
Reply to  jon
May 13, 2017 12:51 am

Or another demanding that the EPA states whether any finding or regulation is based on measurement or on modelling?

Dodgy Geezer
May 13, 2017 1:50 am

how about stopping using the Linear No-threshold model for damage estimation?

Mark from the Midwest
May 13, 2017 4:42 am

Reminder!!! Comment period applies to all Federal Agencies, not just EPA … I’m working on, or have submitted for Commerce, Health and Human Services, and Interior … and also Fed mandates on bio-fuels

Resourceguy
Reply to  Mark from the Midwest
May 13, 2017 2:01 pm

Where??? I want to go after the biofuel hegemony and Iowans in general.

Mark from the Midwest
Reply to  Resourceguy
May 13, 2017 4:31 pm

Not everything is due in the next 3 days, and you need to do a little searching. Go to REGULATIONS.GOV and look at the header that says “due in the next … days” and also look at the filters, on the left, that deal with different agencies. If there is not already a bio-fuels showing up under Agriculture I’ll try and get you the exact link, I think the comment period will remain open for more than a month

ralfellis
May 13, 2017 6:45 am

I sent this little missive:
Determination of true DLR trends, to determine the true effects of increasing CO2.
Dear EPA,
Many EPA regulations take Global Warming into account. But is Global Warming real? There is an easy way to test this hypothesis.
Greenhouse gasses work by trapping ‘heat’ under a ‘blanket’ of H2O or CO2. So the greenhouse effect can be directly measured by measuring DLR (Downwelling Longwave Radiation). This is not a measurement of surface temperatures, which can be effected by many other factors – instead it is a direct measurement of the actual greenhouse effect.
But in all the studies I have seen, there has been NO increase in DLR. Take a look at the enclosed graph of equatorial DLR. Notice any rise in DLR here? No – none.
Please note – if there is no increase in DLR, then increasing CO2 CANNOT be causing any increase in surface temperatures.
Before spending any further monies chasing a pseudo-science mythology, please can you undertake a complete review of all the DLR records you can obtain. Otherwise, you may be wasting billions of our tax dollars.
Sincerely
……….
The Image is from Willis Eschenbach’s posting:
https://wattsupwiththat.com/2015/02/21/the-tao-calculated-surface-datasetscomment image

May 13, 2017 1:55 pm

This particular .gov website will not display on my computer, because, apparently Firefox refuses now to deal with Java scripted sites. Internet Explorer won’t show it either, because of some problem with the security certificate. No comments from me, therefore.

May 13, 2017 2:58 pm

Forgive my density on this suggestion to submit comments, but it is not at all clear to me what it is one might comment on EXACTLY at that .gov website. It seems very obscure. EXACTLY what are we to comment on?
I got to the website, against Internet Explorer’s warning about the security certificate, and I saw nothing there to guide one on what EXACTLY the subject of commentary was.
I’m not getting it. In order to comment, I need an exact topic, an exact list from which to choose subjects about which to comment, … SOMETHING … a summary, a guide, some directions. All I see is obscurity on top of obscurity, with no directions to focus on why I would be saying anything about anything. And then I see this bunch of comments that seem to be out of the blue and unrelated to anything specific presented on the page motivating such comments.
Either the website is expecting way too much of a person’s knowledge, or I have just discovered proof of my mental incompetence.

Jeanine Schmidt
May 13, 2017 4:23 pm

Please submit as many specific regulatory change suggestions as you can. There are dozens of EPA issues (toxic release inventory; State primacy on dredge- and fill permits; their re-definition of “waters of the US”, wetlands and permafrost permitting etc. ) that make little sense, are contradictory or impossible to fulfill or are in need of modification. But the majority of comments on the website to date are of the “the EPA is perfect – any attempts to change anything at all will kill my children and destroy the earth” variety (i.e. useless to the agency). It’s a rare chance to improve things.

May 13, 2017 8:17 pm

How do I find out if they have any Artic regulations? If so, I would have contributions.

David S
May 14, 2017 10:06 am

Simple; the very first sentence in the very first article of the constitutions says “All legislative powers herein granted shall be vested in a Congress of the United States, which shall consist of a Senate and House of Representatives.” Note that it doesn’t mention the EPA or any other federal agency. Yet the EPA creates regulations which carry the force of law. That is clearly unconstitutional. And its a great danger because it means we have in effect laws created by unelected and unaccountable bureaucrats instead of our elected representatives and senators. So all EPA regulations should be scrapped. Any of those regulations that we really need should be enacted by congress. The rest should be gone.

David S
Reply to  David S
May 16, 2017 7:10 am

Those laws seemingly delegate congress’ law making authority to the EPA, but there is no provision in the constitution that says congress can delegate its powers to anyone.